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Comment 6 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 15-2.

First NameJim
Last NameMeyer
Email Addressjmeyer@aviation-repair.com
Affiliation
SubjectFugitive Emissions Cancer Risk Estimate
Comment
A key accusation made by CARB against the metal finishing industry
is that fugitive emissions may be equally or even more dangerous to
the public than stack emissions. I have previously commented on the
fiction that cancer risk from stack emissions equals 213 in a
million from large chrome plating facilities. Now, it is time to
examine the fiction that fugitive emission cancer risks can range
to 1,000 chances in a million. 
The section quoted below is taken directly from Pages F-49 and F-50
of CARB's posted materials. 
BEGINNING OF QUOTE
"Based on the assumptions and model setup described above, staff
estimated potential cancer risks ranging from one chance per
million to greater than 1,000 chances per million. 
4. Conclusion
Staff recognizes that this is a high-level directional analysis and
is not intended to definitively estimate fugitive emissions rates
from specific chrome plating facilities. Nevertheless, the
assumptions made are reasonable and this analysis provides
information regarding what the potential cancer risks from fugitive
emissions might be. Based on these results, it is reasonable to
conclude that fugitive emissions of hexavalent chromium from chrome
plating facilities are likely to contribute to cancer risks in
communities surrounding such facilities."
END OF QUOTE
The quote specifically states that "The assumptions made are
reasonable". You can be the judge. The entire model is described on
pages F-45 to F-51.
As you can see in the first sentence, CARB is describing the cancer
risk model and the data they used to generate their estimate. It is
a complex model, and they describe it over several pages. As with
all models, it is sensitive to the assumptions made and it is
particularly sensitive to the initial data inputs. In this case,
CARB does not distinguish themselves. They first attempt to answer
the question "how much hex chrome is emitted from an uncontrolled
tank?" Surprisingly, CARB does not quote any electrochemical
science to answer this question. There is no reference to any
science that shows what amount of hex chrome would be dispersed
during a plating operation. Are we to believe that in 100 years of
chrome plating, no scientist or chemical engineer has ever
documented (or computed) the amount of hex chrome mist that comes
from uncontrolled tanks? Are we also to believe CARB and/or AQMD in
over 30 years of regulating chrome plating tanks have never done
any math to compute hex chrome emissions from uncontrolled tanks?
CARB should answer these questions because without answers a
reasonable person could conclude that established scientific facts
did not support CARB's pre-ordained conclusions and had to be
dismissed. 
So, in the absence of science fact, here is the method they used to
deduce that uncontrolled tanks produce 1 mg per amp hour of hex
chrome emissions. They assumed that emissions are a function of two
variables: 1) The arbitrary rule limit for fume
suppressant-controlled tanks, and 2) The top-end of the
manufacturers stated control efficiency of fume suppressants. Both
variables happen to equal 0.1. So, dividing one into the other CARB
assesses that the physical chemical electroplating process produces
1 mg per amp hour (0.1 / 0.1 = 1.0). There it is, feed it into the
cancer risk model. Some of you are getting the drift here. You can
already see that if there was any actual emission science behind
the suppressant rule limit of 0.1, CARB could (or would, or should)
have used it. You might also question how they decided to use 99%
efficiency as their fume suppressant value when they could have
used 95%. The answer to that is simple, the 99% assumption drives a
higher risk value and supports the desired answer to this "study".
But wait, perhaps I am too hasty in attributing to malice that
which can be explained in other ways, it is possible that a summer
intern performed this analysis and that perhaps the deficiency is a
simple lack of quality assurance, audit function, and management
oversight. I can't say. 
Since I believe there are certain science facts relating to
physical processes in nature, I don't buy into using the equation
on page F-46 (and shown below) as the basis for the starting point
to estimate fugitives. Neither should you.
"Uncontrolled tank emissions = 0.01 (mg / amp hr) / (1-0.99)" = 1
mg per amp hr
But let's give the intern the benefit of the doubt because maybe he
only had a couple of hours to produce some data to back up the
conclusions about fugitives that he was told to create.
QUESTION FOR CARB - WHAT IS THE HEX CHROME EMISSION RATE FROM
UNCONTROLLED TANKS? You have been regulating these tanks for
decades. Please cite scientific papers or AQMD studies to answer. 
Wait, there is another troubling aspect to this. Because once we
calculate uncontrolled tank emissions, we must figure out what
percent of the emissions get past the control systems. CARB was
able to locate a US EPA manual about hoods from 1986. They wiped
the dust from it, sneezed a couple of times, and ignored the fact
that it pre-dated even their first chrome ATCM back in 1988. Now,
36 years later, they chose to construct an estimate of hood capture
efficiency by examining it. The book said capture efficiency ranged
from 50% to 100%. Yes, that is a wide range. Yes, that range
includes 100% - even in 1986. But the intern, or whoever wrote this
section, or whoever reviewed the work, makes the following
statement. 
QUOTING
"The plating industry uses a different style of hood, but lacking
better information about its performance, staff chose to evaluate
fugitive emissions using a range of capture efficiency from 85
percent to 95 percent."
END QUOTE 
Are you kidding me? Is CARB so unaware that the source tests that
the air districts require, and that we pay $20,000 to execute, have
rules about hood capture efficiency? Really? Is CARB aware that
this very proposed rule I am commenting on, requires 100% hood
capture efficiency by virtue of CARB finally adopting AQMD Rule
1469? Hey CARB, this is how it works. The air districts review and
approve our test protocols prior to the test. Then they monitor the
test while it is performed. During the test, they observe the slot
velocities, and we record them. We must perform video taped smoke
tests as confirmation that they capture 100%. Only then, once 100%
capture is assured, the HEPA source test is conducted. Following
that, for the next few years until the next source test is
performed, we are required to maintain the minimum slot velocities
and perform ongoing video taped smoke tests to assure that we are
always achieving a 100% capture rate. We must keep ongoing records
of all this. Inspectors come and review our records and the smoke
test videos.
The 1,000 chances in a million-cancer risk assertion from fugitive
emissions is garbage. It is garbage because the two input variables
to your cancer risk model are shown to be garbage.
Here is my question for CARB - Is this a case of simple ignorance
by CARB? Maybe combined with a lack of management oversight, poor
quality assurance, maybe no audit function? Or is it malicious?
I know it will be tempting for you to simply declare that this
comment is out-of-bounds. That it is not relevant to the fact that
you simply changed the decimal point on your computed average of a
few source tests. But here is the situation. We are talking about
truth and the lack of truth and where CARB stands with respect to
the truth about emissions. CARB wants to portray itself as the
premier air pollution regulator in the world. To be the leader you
must have credibility. To have credibility, you must embrace truth.
At this point, it is obvious, South Coast AQMD is the world's
premier air regulator.  If you do not embrace the truth, you will
lose credibility in your other work, which, as I understand it,
involves saving the world. 

Please note also, that on April 14, 2023, two weeks prior to CARB
release of the corrected source test numbers on April 27, I alerted
Steven Cliff, PhD and Edie Chang to this issue in advance with a
heads-up as follows: 

BEGIN QUOTE
"SC AQMD Rule 1469 requires ongoing smoke test validation and
periodic monitoring of slot velocities to assure the push/pulls are
capturing 100%. We validate this in our source tests. Despite that,
the CARB estimate is somewhere between 85% and 95% according to
your text and the footnoted source is a tech manual from 1986. 
The assumption and math that was used to get to the 1 mg / amp hour
tank rate is suspect since the rule limit used to start that
equation is arbitrary to start with."
END QUOTE

By all appearances, CARB has chosen not to correct the record
regarding the critical element of fugitive emissions. 

Attachment
Original File Name
Date and Time Comment Was Submitted 2023-04-29 18:55:29

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